Finding 1205095 (2025-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-31

AI Summary

  • Core Issue: Inaccurate reporting of student financial data to the COD system, with 9% of origination reports containing errors.
  • Impacted Requirements: Compliance with 34 CFR § 668.408(a)(2) regarding accurate reporting of student enrollment and cost information.
  • Recommended Follow-Up: Implement control procedures to ensure that reported data aligns with supporting documentation in student files.

Finding Text

34 CFR § 668.408(a)(2) states in accordance with procedures established by the Secretary, an institution offering any group of substantially similar programs in any student financial assistance program authorized by Title IV of the Higher Education Act of 1965, as amended, must report to the Department for each student: • (i) information needed to identify the student and the institution; • (ii) the date the student initially enrolled in the program; • (iii) the student's attendance dates and attendance status in the program during the award year; • (iv) the student's enrollment status as of the first day of the student's enrollment in the program; • (v) the student's total annual cost of attendance; • (vi) the total tuition and fees assessed to the student for the award year; • (vii) the student's residency tuition status by State or district. The U.S. Department of Education requires institutions to submit Direct Loan and Pell Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. Due to insufficient controls over reporting in the COD system, one out of eleven (9%) of origination reports were inaccurately submitted in the COD system. We noted the reported cost of attendance for one student did not agree with the supporting documentation in the student's file. This weakness resulted in a loss of accountability over origination records reporting and could lead to a reduction or forfeiture of future funding for this program. The School District should develop control procedures and policies to help ensure the origination records reported to the COD system agree with the underlying supporting documentation in the student files.

Corrective Action Plan

The District acknowledges the finding related to the reporting of origination records to the Common Origination and Disbursement (COD) system in accordance with 34 CFR § 668.408(a)(2). The determination is that the discrepancy was the result of a manual data entry error during the preparation and submission of the origination record. The issue was isolated to a single record within the sample reviewed and does not reflect a systemic reporting issue. Upon identification, the District verified the correct cost of attendance information in the student’s file and updated the record in the COD system to ensure it accurately reflects the supporting documentation. The District recognizes the importance of Title IV funding and takes the accuracy of Title IV reporting seriously and has implemented additional internal control procedures to strengthen oversight of origination record submissions, including a secondary review of key data elements, such as cost of attendance, prior to submission of origination records to the COD system and ensuring all required data fields align with the student’s supporting documentation. These corrective actions are intended to ensure that the information reported in the COD system is accurate and consistent with the documentation maintained in student files, thereby maintaining compliance with federal reporting requirements and safeguarding the integrity of Title IV program administration.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1205094 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $1.18M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $681,642
84.268 FEDERAL DIRECT STUDENT LOANS $398,834
84.063 FEDERAL PELL GRANT PROGRAM $377,367
10.555 NATIONAL SCHOOL LUNCH PROGRAM $215,204
10.553 SCHOOL BREAKFAST PROGRAM $57,719
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $6,457
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $3,809